Free Letter - District Court of Delaware - Delaware


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Date: September 10, 2008
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State: Delaware
Category: District Court of Delaware
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Case 1 :06-cv—00275-GIVIS Document 133 Filed 08/13/2008 Page 1 of 1
Reed Smith LLP
1201 Market Street
Suite 1500
Wilmington, DE 19801-1163
Thad J. Bracegirdle +1 302 778 7500
Direct Phone: +1 302 778 7571 Fax +1 302 775 7575
Email: [email protected] reedsmitlmoom
August I3, 2008
Bv CMJECF
The Honorable Gregory M. Sleet
U.S. District Court for the District of Delaware
844 North King Street, Lock Box l9
Wilmington, DE 19801
Rc: Chris! v. Ccrmick, C.A. Ne. 06-275-GMS
Elm: Suisse Ltd. v. Christ, C.A. N0. 07-60-GMS
Dear Chief Judge Sleet:
On behalf of Robert D. Christ, I write to advise the Court of a recent event that is relevant to Mr.
Christ’s pending Motion for Default Judgment and Attomeys’ Fees (D.I. 128). As of August 6, 2008,
Elan Suisse Ltd., the plaintiff in Civil Action No. 07-60—GMS, was finally dissolved at Brett Cormick’s
request. (Confirmation from the United Kingdom Companies House of Elan Suisse Ltd.’s dissolution is
enclosed for the Court’s reference.) As the Court may recall, Mr. Christ had sought reimbursement from
this entity of at1omeys’ fees incurred in defending its frivolous claims. See D.I. I29 at 6-7. Upon its
dissolution, however, any assets held by Elan Suisse Ltd. became bona vaccmria and automatically
passed to the Crown under English law. See D.I. 61 at 20.
The dissolution of Elan Suisse Ltd. highlights Mr. Christ’s growing fear that, as time passes, any
judgment against Mr. Cormick and his affiliated entities will become more and more difficult to enforce.
At this stage of the proceedings, the Court already has entered a default against defendants andthe only
remaining issue to be resolved is the judgment amount. Accordingly, and for the reasons set forth in his
pending motion, Mr. Christ respectfully requests that the Court enter judgment against Mr. Cormick and
Elan Suisse International Holdings (USA) LLC so that collection efforts may begin as soon as possible.
Respectfully,
Thad J. Bracegirdle g
(Del. Bar No. 3691)
Enclosure
cc: Clerk ofthe Court (by CM/ECF, w/encl.)
David L. Finger, Esquire (by CMIECF, wfencl.)
NEW YORK • LONDON •» HONG KONG • CHICAGO •WA5HINGTON, D.C. • BEIJING • PARIS • LOS ANGELES • SAN FRANCISCO • PHILADELPHIA ·•» PITTSBURGH
OAKLAND •· MUNICH • ABU DHABI • PRINCETON •» NORTHERN VIRGINIA • 'W‘.lLMINGTON• BIRMINGHAM • DUBAI • CENTURY CI`I’Y• RICHMOND • GREECE
WILLIB-55329 I

C¤1‘¤p@H&iEliE—cv-00275-GIVIS Document 133-2 Filed 08/13/2008 Page 1 oiizfgel oi`]
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....,.,.. .......
Q Company Details r
i Name & Registered Office:
{ ELAN SUISSE LTD 1
2 LANSDOWNE ROW, BERKELEY SQUARE g
MAYFAIR
LONDON ·
' W1J s1—11. l
l Company Nc. 04998672 1
E Status: Dissolved 08/08/2008
Date of Incorporation: 18/12/2003
Country of Origin: United Kingdom
Company Type: Private Limited Company
Nature of Business (SIC(03)):
7414 - Business & management consultancy
Accounting Reference Date: 31/12 l
l Last Accounts Made Up To: 31/12/2006 (DORMANT) ·
i Next Accounts Due: E
Q Last Return Made Up To: 18/12/2006 `
l Next Return Due:
. Last Members List: 18/12!2006
; Previous Names:
i No previous name information has been recorded over the last 20 years.
I Branch Details
1 There are no branches associated with this company.
Oversea Company info
i There are no Oversea Details associated with this comp@yL__ ______